Corrective Action Plans

(B) The Department will review and revise, as necessary, its taxi claim billing requirements and rates to ensure that they are consistent. In addition, the Department will devise controls to ensure that taxi claims are paid in accordance with established requirements and rates and explore controls to ensure that only permitted providers bill as a taxi. The Department is working on reductions in the max fee and unit limits for taxi claim billing codes, which it will have completed by the end of October 2021. In addition, the Department is considering systematically pricing the code at each taxi provider?s specific Public Utilities Commission (PUC) rate. This change, if pursued, will require a system change request, which will take a year or more, which is why the Department has selected an implementation date of December 2022. If this proves infeasible, alternate controls will be implemented. HCPF has met with DORA PUC. The Department is trying to establish a process to decide if the PUC taxi rate still applies or an internal rate can be created. Because of these discussions and needed system changes the implementation date has been moved to December 2023. (D) The Department intends to define in rule the types of documentation that NEMT providers must keep on hand and make clear that they must furnish records to the Department upon request. The July 2022 date will allow for the completion of formal rulemaking. The Department further intends to develop and implement a process to perform regular risk-based provider file reviews with a focus on noncompliant providers. These reviews will ensure, at a minimum, that the providers? paid claims are supported with appropriate documentation and represent the least costly option appropriate to meet each recipient?s needs. The Department met with the RAC team on February 22, 2023 to come up with a process to perform small audits for claims from providers that are outside the Intelliride service area. New systems will be implemented which has pushed the anticipated completion date to December 2023. (E) The Department will amend its contract with its NEMT broker by adding a mandatory annual audit so that it can reconcile trip scheduling data with paid claims data. This will help ensure that the Department pays accurately, pays for NEMT services, and pays for the least costly transportation option appropriate for each recipient. The Department chose July 2022 to add the audit through its annual contract amendment and renewal processes. The contract amendment was completed and signed June 30, 2022 that included a clause for an annual audit of claims. (F) The Department will develop a data review process to reconcile interChange data on NEMT trip claims to interChange data on Medicaid medical claims. This process will entail periodic reviews of NEMT claims to see if members have corresponding medical claims on those dates. If they do not, the Department will follow up with the appropriate NEMT provider to investigate. The July 2022 implementation date reflects the potential need for system changes. This is implemented, the Department has been pulling claims data and where corresponding medical claims are not found HCPF is investigating on a case by case basis to find the cause. (G) Department staff will work with the Department?s Program Integrity (PI) staff on processes to investigate and recover, as appropriate, the overpayments and inappropriate payments that the audit identified as known or likely questioned costs, and repay the federal portion, as appropriate. The December 2022 implementation date reflects the time needed to investigate and when appropriate, recover any overpayments. This has been implemented and the federal portion has been returned to CMS. (H) The Department will develop a process to track staff time and productivity to ensure that it has sufficient staff assigned to oversee and administer NEMT. This process will include documenting time spent each week on various tasks to get a sense of where help is needed, and which tasks take up the most staff resources. Based on its findings, the Department will explore staffing options, as needed. The Department selected the July 2022 implementation date to allow for data collection through the end of State Fiscal Year 2021-22. This has been implemented. New NEMT staff was hired November 1, 2022 to act as the liaison to the counties and clients in the 55 counties outside of the Intelliride service area.

Finding 2022-001: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. During the course of the Ochsner Clinic Foundation Uniform Guidance (UG) Audit for the Year Ended December 31, 2022, EY identified the following finding, as reported in the Schedule of Findings and Questioned Costs: Finding 2022-001 - Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. This finding is associated with application numbers PA-06-LA-4611-PW-01437 and PA-06-LA-4611-PW-01457. Both of these Project Worksheets (PWs) are for external security services that Ochsner procured in the aftermath of Hurricane Ida. These PWs included a population of 130 expenditures (invoices) for a total value of $923,105 (total value factoring in the cost share was $888,900). FEMA obligated these PWs and payment was remitted to Ochsner (via GOHSEP) for the full cost share amount of $888,900. As part of their testing over activities allowed or unallowed, allowable costs/cost principles, and period of performance, EY selected a sample of 45 items from this population ? 21 for testing over activities allowed or unallowed and allowable costs/cost principals and 24 for testing over period of performance. Through their testing, EY identified certain expenditures in the sample that were not reduced for all applicable credits (i.e., the vendor provided a credit back to Ochsner for a previously paid invoice). As a result of these items identified in the sample, Management evaluated the entire population of expenditures, and identified $99,285 as the difference between the submitted expenditures value to FEMA and the expenditures value after reducing for all applicable vendor credits. Ochsner did not identify these discrepancies when the PWs were filed with FEMA because the vendor invoices were used as the basis for the estimate of the claims, which is consistent with FEMA?s requirements. These vendor invoices reflected the full amounts billed by the vendor and did not reflect any credits that ultimately resulted in lesser amounts being remitted to the vendor at time of payment. The discrepancies that EY identified during the UG audit would have been identified, as is usually done, by either Ochsner or by FEMA / GOHSEP during the normal closeout process for these PWs, as discussed within the Public Assistance Program and Policy Guide (Version 4, Effective June 1, 2020) - Chapter 12: Final Reconciliation and Closeout. As part of this standard process, Ochsner will be required to provide proof of payment to FEMA / GOHSEP as part of the closeout process, at which time these discrepancies would have been identified. In order to cure this finding, Ochsner will reach out to FEMA / GOHSEP to self-report the issue and ask that these PWs be moved to closeout (this can be done because both PWs have been paid in full). Ochsner will also work with FEMA / GOHSEP to refund the total overpayment of $99,285 ? either via direct payment or reduction of future reimbursement under Ochsner?s other outstanding PWs with FEMA for COVID-19 and Hurricane Ida. For future FEMA claims, Ochsner will continue to work to ensure that PWs are reduced for all applicable credits using the most accurate information available ? either at the time the PWs are submitted or during closeout. Responsible Official: Scott Whitfield, Ochsner Assistant Vice President - Treasury Anticipated Completion Date: December 31, 2023

Finding 2022-001 Management will develop and implement an additional layer of review in future Federal Emergency Management Agency (FEMA) project worksheet submissions to ensure expenditures reported for reimbursement are based on actual paid expenditures. Management will work with FEMA to refund the total overpayment of $904,020 and discuss the extent of additional courses of action. Management will ensure this is performed through the closeout process of the project worksheet with FEMA. Contact Person: Colette Boudreau, Vice President and Chief Accounting Officer Expected Completion Date: October 31, 2023

In each of our districts we will practice oversight and due diligence over the documentation of Disaster Grant expenditures. We will review documents to ensure labor rates and equipment rates were those approved FEMA. We will acknowledge our review by signing the documents.

The County will establish policies and procedures to create better communication between the Emergency Manager and the County Officers.

Title 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters), Responsible personnel will attend training classes by OSAI, OEM, and Muskogee Creek Nation to stay updated on allowable expenditures and record keeping techniques to allow for more accurate reporting. I will work with the County Emergency Management Coordinator to ensure quarterly reports are filed on time., Responsible Contact Person Board of County Commission Chairman - James Yandell